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HIPAA Layered Privacy Notices

HIPAA Layered Privacy Notices. HIPAA Summit March 27, 2003. HIPAA Layered Privacy Notices. HHS has “encouraged” use of a “layered notice” A short notice that briefly summarizes relevant information Longer notice contains all required elements. Layered Privacy Notices.

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HIPAA Layered Privacy Notices

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  1. HIPAA Layered Privacy Notices HIPAA Summit March 27, 2003

  2. HIPAA Layered Privacy Notices • HHS has “encouraged” use of a “layered notice” • A short notice that briefly summarizes relevant information • Longer notice contains all required elements

  3. Layered Privacy Notices • Two functions of a privacy notice: • Accountability function • Communications function • Legally complete, long notice satisfies accountability function • Highlights notice serves communications function • Contains key elements • Provides clear understanding of how PHI is used/disclosed and rights of individuals Important to get HIPAA notices right or risk losing critical trust of patient

  4. HIPAA Highlights Notice • Short • No more than 7 elements • Simple vocabulary • No need to translate or work hard to read • Graphically-designed format for ease of reading and comparison • Competing styles and formats make notices difficult to process

  5. HIPAA Highlights Notice Project • Center for Information Policy Leadership at Hunton & Williams led group of health care privacy leaders to prepare Highlights Notice Template • Hi-Ethics • WellMed • VHA • OTN (BMS subsidiary) • American Specialty Health • Emory University • Developed prototype

  6. HIPAA Highlights Notice Template: Challenges • Determined which categories are critical • What do health care consumers want to know? • What is it important for covered entities to tell consumers? • Distilled 30-plus required categories into 5 key categories • OK to issue notice that is not legally compliant?

  7. HIPAA Highlights Notice Template • Used simple words to define complex terms • “Health care operations” • “Accounting” • Long deliberations to choose appropriate phrases and vocabulary

  8. HIPAA Highlights Notice Template • Preamble: Explanation and reference to complete notice • Categories: • Scope • Difficult to describe various structural relationships (e.g., ACE’s, OHCA’s)

  9. HIPAA Highlights Notice Template • Uses and Disclosures • Distilled all possible PHI uses/disclosures into a few key entries • TPO • Research • Public health uses • Fundraising • Marketing (or not) • Any other use/disclosure requires permission

  10. HIPAA Highlights Notice Template • Your Rights and Choices • Access, amendment, accounting • Other Important Information • Optional: Could discuss fundraising, marketing, seal programs • How To Reach Us • 3 methods

  11. HIPAA Highlights Notice Template: Next Steps • HHS has vetted Template in several meetings • Template incorporates HHS suggestions • Preparing User’s Guide and Design Guide • Focus group testing conducted on Template by Electronic Ink • Discussions with trade and industry associations, health care advocates, state and federal regulators

  12. Questions? Lisa J. Sotto (212) 309-1223 LSotto@Hunton.com 158423v2

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